The New Privacy Officer
tions bundled it into the HIM director’s responsibilities. At the
time it seemed like a manageable request, and many HIM direc-tors/privacy officers took on the role as “other duties assigned,”
Davis says.
But as the responsibilities and workload increased over the
years, the privacy duties have required more and more time of
otherwise busy HIM directors. Splitting off the role into its own
position, however, is not always possible, especially at smaller
facilities.
Combining too many roles—HIM director/privacy officer/se-curity officer/compliance officer, for instance—can cause erosion in each of those disciplines, Hofman notes.
“You are not going to have a lot of time to focus on your priva-
cy initiatives if you are a medical records director running cod-
ing with ICD- 10,” she says. “Organizations need to be careful as
they try to streamline positions.”
In California, privacy officers were adapting to a stringent
new state law on breach notification in the months before HI-
TECH was passed. The California law mandates breach report-
ing within five days of discovery, the strictest requirement in the
country.
Daniel Pothen, MS, RHIA, CHPS, CCS-P, serves as the director
of clinical informatics/HIS/privacy officer at Mission Hospital
based in Mission Viejo, CA. He has seen the privacy officer portion of his job increase in importance in the years since the state
and federal breach laws were passed.
California’s breach law required Pothen to rework the organization’s breach policies and educate staff on the new requirements. When the federal breach notification law took effect
later that year, Pothen and other privacy officers statewide had
to assess its requirements against their state law to ensure their
organizational practices would keep them compliant with both
regulations.
Breach investigations continue to eat up time for multirole
Chris Dimick ( chris.dimick@ahima.org) is staff writer at the Journal of
AHIMA. CARE22112_ICD10approved_layout2:Layout 1 2/17/12 10: 41 AM Page 1
privacy officers like Pothen. California’s five-day notification
deadline adds urgency to the effort.
“It is very time intensive when you have to basically stop what
you are doing, drop everything, and investigate a suspected privacy breach,” Pothen says.
Pothen has turned to his compliance coordinator for help
when breaches occur, which allows him to meet the five-day
notification law while also handling his other duties as director
of clinical informatics and health information services. Strong
management support has also helped him fulfill his various responsibilities—something that is essential today for all multirole privacy officers.
As privacy officers become busier, they need to develop their
skills in collaborating with other staff members to share and leverage work, Hofman says.
They need to assess what they are doing internally and then
seek out potential partners who are addressing the same issues.
As more duties are handed to the privacy officer over the coming years, Dinh foresees the role becoming a full-time position
at most facilities.
“There is a good possibility that the privacy officer’s responsibilities are going to become so big that being the HIM director/
privacy officer won’t be an option. It will become a position of
its own,” she says.
At its core, the privacy officer’s duty remains unchanged; however, the role has changed greatly since it was conceived as a
temporary or part-time position back in 2002, Davis says.
“I think when we went into this 10 years ago we didn’t know
what we would be doing and how long we would be doing it for,”
she explains. “There is much greater definition of the role now,
there is greater responsibility, and great recognition.” ¢
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